Looks like it, yes. I don't use any special private APIs, just the public ones that you can use in apps on the app store. They need the accessibility permission to "Control your computer". Apps like BetterSnapTool/Magnet work with the same permission. Here's the code that actually intercepts scroll events: https://github.com/ther0n/UnnaturalScrollWheels/blob/master/...

I think the accessibility API lets you do this, although you might need to explain why you're using it during app review.